Summary
- The ITAT Mumbai has quashed a ₹16.20 lakh reassessment, ruling that the Assessing Officer improperly invoked Section 147 and 148, bypassing the required Section 153C procedure based on third-party search material.
- This decision stemmed from a search on the Rajesh Lifespaces Group, where alleged cash payments for a flat purchase were identified.
- The Tribunal followed the Bombay High Court's precedent in Sejal Jewellary, emphasizing that the statutory route must be adhered to when using search-derived information.
- The ruling underscores the importance of jurisdictional compliance in tax assessments, leaving open questions about the validity of similar cases under different legal interpretations.
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